APENNDIX A 

 
A‐2

APPENDIX A - LIST OF TABLES 

Table A-1. Cost of Implementing Equipment Leak Monitoring Program at a Well Site 

(Assumes fugitive emissions monitoring using Method 21 (10,000 ppm Leak Definition)).....................................A‐5

Table A-2. Cost of Implementing Equipment Leak Monitoring Program at a Well Site 

(Assumes fugitive emissions monitoring using Method 21 (2,500 ppm Leak Definition)).......................................A‐6

Table A-3. Cost of Implementing Equipment Leak Monitoring Program at a Well Site 

(Assumes fugitive emissions monitoring using Method 21 (500 ppm Leak Definition))..........................................A‐7

Table A-4. Cost of Implementing Equipment Leak Monitoring Program at a Compressor Station 

(Assumes fugitive emissions monitoring using Method 21 (10,000 ppm Leak Definition)).....................................A‐8

Table A-5. Cost of Implementing Equipment Leak Monitoring Program at a Compressor Station 

(Assumes fugitive emissions monitoring using Method 21 (2,500 ppm Leak Definition)).......................................A‐9

Table A-6. Cost of Implementing Equipment Leak Monitoring Program at a Compressor Station 

(Assumes fugitive emissions monitoring using Method 21 (500 ppm Leak Definition))........................................A‐10

Table A-7. Cost of Implementing OGI Monitoring Program at a Well Site ............................................................A‐11

Table A-8. Cost of Implementing OGI Monitoring Program at a Compressor Station (Gathering and Boosting)..A‐12

Table A-9. Cost of Implementing OGI Monitoring Program at a Compressor Station (Transmission) ..................A‐13

Table A-10. Cost of Implementing OGI Monitoring Program at a Compressor Station (Storage)..........................A‐14

Table A-11. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 Monitoring 

(10,000 ppm Leak Definition; Single Pollutant)......................................................................................................A‐15

Table A-12. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 Monitoring 

(10,000 ppm Leak Definition; Single Pollutant)......................................................................................................A‐15

Table A-13. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 Monitoring 

(10,000 ppm Leak Definition; Multi-Pollutant).......................................................................................................A‐16

Table A-14. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 Monitoring 

(10,000 ppm Leak Definition; Multi-Pollutant).......................................................................................................A‐16

Table A-15. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 Monitoring 

(2,500 ppm Leak Definition; Single Pollutant)........................................................................................................A‐17

Table A-16. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 Monitoring 

(2,500 ppm Leak Definition; Single Pollutant)........................................................................................................A‐17

Table A-17. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 Monitoring 

(2,500 ppm Leak Definition; Multi-Pollutant).........................................................................................................A‐18

Table A-18. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 Monitoring 

(2,500 ppm Leak Definition; Multi-Pollutant).........................................................................................................A‐18

Table A-19. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 Monitoring 

(500 ppm Leak Definition; Single Pollutant)...........................................................................................................A‐19

Table A-20. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 Monitoring 

(500 ppm Leak Definition; Single Pollutant)...........................................................................................................A‐19

Table A-21. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 Monitoring 

(500 ppm Leak Definition; Multi-Pollutant)............................................................................................................A‐20

Table A-22. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 Monitoring 

(500 ppm Leak Definition; Multi-Pollutant)............................................................................................................A‐20

Table A-23. Nationwide Impacts – Method 21 Monitoring and Repair Plan - 2020 (Well Sites)...........................A‐21

Table A-24. Nationwide Impacts – Method 21 Monitoring and Repair Plan - 2025 (Well Sites)...........................A‐23

Table A-25. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/o Recovery 

Credits – M21 Monitoring (10,000 ppm Leak Definition).......................................................................................A‐25

Table A-26. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/ Recovery 

Credits – M21 Monitoring (10,000 ppm Leak Definition).......................................................................................A‐26
A‐3

Table A-27. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/o Recovery 

Credits – M21 Monitoring (2,500 ppm Leak Definition).........................................................................................A‐27

Table A-28. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/ Recovery 

Credits – M21 Monitoring (2,500 ppm Leak Definition).........................................................................................A‐28

Table A-29. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/o Recovery 

Credits – M21 Monitoring (500 ppm Leak Definition)............................................................................................A‐29

Table A-30. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/ Recovery 

Credits – M21 Monitoring (500 ppm Leak Definition)............................................................................................A‐30

Table A-31. Nationwide Impacts – Method 21 Monitoring and Repair Plan - 2020 (Transmission & Storage 

Facilities)..................................................................................................................................................................A‐31

Table A-32. Nationwide Impacts – Method 21 Monitoring and Repair Plan - 2025 (Transmission & Storage 

Facilities)..................................................................................................................................................................A‐33

Table A-33. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – Annual 

OGI Monitoring (Single Pollutant) ..........................................................................................................................A‐35

Table A-34. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Annual 

OGI Monitoring (Single Pollutant) ..........................................................................................................................A‐35

Table A-35. OGI- Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – Annual 

OGI Monitoring (Multi-Pollutant) ...........................................................................................................................A‐36

Table A-36. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Annual 

OGI Monitoring (Multi-Pollutant) ...........................................................................................................................A‐36

Table A-37. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – 

Semiannual OGI Monitoring (Single Pollutant).......................................................................................................A‐37

Table A-38. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – 

Semiannual OGI Monitoring (Single Pollutant).......................................................................................................A‐37

Table A-39. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – 

Semiannual OGI Monitoring (Multi-Pollutant)........................................................................................................A‐38

Table A-40. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – 

Semiannual OGI Monitoring (Multi-Pollutant)........................................................................................................A‐38

Table A-41. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – Quarterly 

OGI Monitoring (Single Pollutant) ..........................................................................................................................A‐39

Table A-42. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Quarterly 

OGI Monitoring (Single Pollutant) ..........................................................................................................................A‐39

Table A-43. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – Quarterly 

OGI Monitoring (Multi-Pollutant) ...........................................................................................................................A‐40

Table A-44. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Quarterly 

OGI Monitoring (Multi-Pollutant) ...........................................................................................................................A‐40

Table A-45. Nationwide Impacts – OGI Monitoring and Repair Plan - 2020 (Well Sites) .....................................A‐41

Table A-46. Nationwide Impacts – OGI Monitoring and Repair Plan - 2025 (Well Sites) .....................................A‐41

Table A-47. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/o Recovery Credits – 

Annual OGI Monitoring (Single Pollutant)..............................................................................................................A‐42

Table A-48. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/ Recovery Credits – 

Annual OGI Monitoring (Single Pollutant)..............................................................................................................A‐42

Table A-49. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/o Recovery 

Credits – Annual OGI Monitoring (Multi-Pollutant)...............................................................................................A‐43

Table A-50. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/ Recovery 

Credits – Annual OGI Monitoring (Multi-Pollutant)...............................................................................................A‐43

Table A-51. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/o Recovery Credits – 

Semiannual OGI Monitoring (Single Pollutant).......................................................................................................A‐44
A‐4

Table A-52. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/ Recovery Credits – 

Semiannual OGI Monitoring (Single Pollutant).......................................................................................................A‐44

Table A-53. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/o Recovery 

Credits – Semiannual OGI Monitoring (Multi-Pollutant)........................................................................................A‐45

Table A-54. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/ Recovery 

Credits – Semiannual OGI Monitoring (Multi-Pollutant)........................................................................................A‐45

Table A-55. OGI - Average Model Plant Cost of Control for Summary Compressor Stations w/o Recovery Credits – 

Quarterly OGI Monitoring (Single Pollutant)..........................................................................................................A‐46

Table A-56. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/o Recovery Credits – 

Quarterly OGI Monitoring (Single Pollutant)..........................................................................................................A‐46

Table A-57. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/o Recovery 

Credits – Quarterly OGI Monitoring (Multi-Pollutant)............................................................................................A‐47

Table A-58. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/ Recovery 

Credits – Quarterly OGI Monitoring (Multi-Pollutant)............................................................................................A‐47

Table A-59. Nationwide Impacts – OGI Monitoring and Repair Plan - 2020 (Compressor Stations).....................A‐48

Table A-60. Nationwide Impacts – OGI Monitoring and Repair Plan - 2025 (Gathering & Boosting Stations) ....A‐49
A‐5

Table A-1. Cost of Implementing Equipment Leak Monitoring Program at a Well Site

(Assumes fugitive emissions monitoring using Method 21 (10,000 ppm Leak Definition)) 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Total

Cost ($/year)

Semiannual

Total Cost

($/year)

Quarterly

Total Cost

($/year)

C

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Note

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitori

people and hours from PES Memora

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (NoteNotification of Initial Compliance Status 1 1 1 $57.80 $1,271.60 $1,271.60 $1,271.60 Assumes that 1 hour is spent to prep

well sites

M21 Monitoring and Data Collection System N/A N/A N/A N/A $25,300.00 $25,300.00 $25,300.00 Includes cost of M21 monitoring dev

($14,500)

First Year Total Hours and Cost per Company 118 $32,120 $32,120 $32,120 Includes read rule and instructions, 

initial survey and notification of init

First Year Total Hours and Cost per Well Site 5.4 $1,460.02 $1,460.02 $1,460.02 Assumes company owns 22 well site

Well Site Level Costs

Subsequent Activities Planning 2 12 24 $57.80 $63.05 $63.05 $63.05 Hours from PES Memorandumb. Tota

well sites per company

Method 21 Survey Cost 2 4 8 $57.80 $462.40 $924.80 $1,849.60 Assumes 2 people and 4 hours per p

monitoring device for each survey

Repair Cost N/A N/A N/A N/A $2,998.68 $2,998.68 $2,998.68 Assumes 7.49% or 41 total leaks fou

*$66.24/hr) and 10 fixed offline (10 

M21 Resurvey Costs N/A N/A N/A N/A $20.00 $20.00 $20.00 Resurvey costs assume cost of $2.00 

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to p

and includes storing/filing of record

Annual Hours and Cost per Well Site 12 $3,775 $4,238 $5,163 Sum of planning, monitoring, repair

Annual Cost with Amortized Capital Cost $4,020 $4,482 $5,407 First year cost per well site cost amo

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 forgeneral and operations managers.b Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAPc The 22 well sites per natural gas production company was derived from the City of Fort Worth Natural Gas Air Quality Study, July 2011.e The component resurvey cost based on the average subsequent moni toring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Led The leak percentage was calculated using the baseline SOCMI emission rate (0.00597 kg/hr/source) and the average leak rate to fraction leaking equations for 10,000 ppmv leak definition in Table 5‐4 of the EPA P

No data was available that included monitoring frequency, therefore i t was assumed that the leak percentage represented the total annual leaks found using Method 21.
A‐6

Table A-2. Cost of Implementing Equipment Leak Monitoring Program at a Well Site

(Assumes fugitive emissions monitoring using Method 21 (2,500 ppm Leak Definition)) 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Total

Cost ($/year)

Semiannual

Total Cost

($/year)

Quarterly

Total Cost

($/year)

C

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Note

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitori

people and hours from PES Memora

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (NoteNotification of Initial Compliance Status 1 1 1 $57.80 $1,271.60 $1,271.60 $1,271.60 Assumes that 1 hour is spent to prep

well sites

M21 Monitoring and Data Collection System N/A N/A N/A N/A $25,300.00 $25,300.00 $25,300.00 Includes cost of M21 monitoring dev

($14,500)

First Year Total Hours and Cost per Company 118 $32,120 $32,120 $32,120 Includes read rule and instructions, 

initial survey and notification of init

First Year Total Hours and Cost per Well Site 5.4 $1,460.02 $1,460.02 $1,460.02 Assumes company owns 22 well site

Well Site Level Costs

Subsequent Activities Planning 2 12 24 $57.80 $63.05 $63.05 $63.05 Hours from PES Memorandumb. Tota

well sites per company

Method 21 Survey Cost 2 4 8 $57.80 $462.40 $924.80 $1,849.60 Assumes 2 people and 4 hours per p

monitoring device for each survey

Repair Cost N/A N/A N/A N/A $5,067.36 $5,067.36 $5,067.36 Assumes 12.25% or 67 total leaks fo

hours *$66.24/hr) and 17 fixed offlin

M21 Resurvey Costs N/A N/A N/A N/A $34.00 $34.00 $34.00 Resurvey costs assume cost of $2.00 

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to p

and includes storing/filing of record

Annual Hours and Cost per Well Site 12 $5,858 $6,320 $7,245 Sum of planning, monitoring, repair

Annual Cost with Amortized Capital Cost $6,103 $6,565 $7,490 First year cost per well site cost amo

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 forgeneral and operations managers.b Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAPc The 22 well sites per natural gas production company was derived from the City of Fort Worth Natural Gas Air Quality Study, July 2011.e The component resurvey cost based on the average subsequent moni toring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Led The leak percentage was calculated using the baseline SOCMI emission rate (0.00597 kg/hr/source) and the average leak rate to fraction leaking equations for 2,500 ppmv leak definition in Table 5‐4 of the EPA Pro

data was available that included monitoring frequency, therefore i t was assumed that the leak percentage represented the total annual leaks found using Method 21.
A‐7

Table A-3. Cost of Implementing Equipment Leak Monitoring Program at a Well Site 

(Assumes fugitive emissions monitoring using Method 21 (500 ppm Leak Definition)) 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Total

Cost ($/year)

Semiannual

Total Cost

($/year)

Quarterly

Total Cost

($/year)

C

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Note

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitori

people and hours from PES Memora

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (NoteNotification of Initial Compliance Status 1 1 1 $57.80 $1,271.60 $1,271.60 $1,271.60 Assumes that 1 hour is spent to prep

well sites

M21 Monitoring and Data Collection System N/A N/A N/A N/A $25,300.00 $25,300.00 $25,300.00 Includes cost of M21 monitoring dev

($14,500)

First Year Total Hours and Cost per Company 118 $32,120 $32,120 $32,120 Includes read rule and instructions, 

initial survey and notification of init

First Year Total Hours and Cost per Well Site 5.4 $1,460.02 $1,460.02 $1,460.02 Assumes company owns 22 well site

Well Site Level Costs

Subsequent Activities Planning 2 12 24 $57.80 $63.05 $63.05 $63.05 Hours from PES Memorandumb. Tota

well sites per company

M21 Survey Cost 2 4 8 $57.80 $462.40 $924.80 $1,849.60 Assumes 2 people and 4 hours per p

monitoring device for each survey

Repair Cost N/A N/A N/A N/A $5,399.88 $5,399.88 $5,399.88 Assumes 13.53% or 74 total leaks fo

hours *$66.24/hr) and 18 fixed offlin

M21 Resurvey Costs N/A N/A N/A N/A $36.00 $36.00 $36.00 Resurvey costs assume cost of $2.00 

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to p

and includes storing/filing of record

Annual Hours and Cost per Well Site 12 $6,193 $6,655 $7,580 Sum of planning, monitoring, repair

Annual Cost with Amortized Capital Cost $6,437 $6,899 $7,824 First year cost per well site cost amo

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 forgeneral and operations managers.b Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAPc The 22 well sites per natural gas production company was derived from the City of Fort Worth Natural Gas Air Quality Study, July 2011.e The component resurvey cost based on the average subsequent moni toring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Led The leak percentage was calculated using the baseline SOCMI emission rate (0.00597 kg/hr/source) and the average leak rate to fraction leaking equations for 500 ppmv leak definition in Table 5‐4 of the EPA Proto

data was available that included monitoring frequency, therefore i t was assumed that the leak percentage represented the total annual leaks found using Method 21.
A‐8

Table A-4. Cost of Implementing Equipment Leak Monitoring Program at a Compressor Station 

(Assumes fugitive emissions monitoring using Method 21 (10,000 ppm Leak Definition)) 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Total

Cost ($/year)

Semiannual

Total Cost

($/year)

Quarterly

Total Cost

($/year)

C

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Not

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitori

people and hours from PES Memora

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (Not

Notification of Initial Compliance Status 1 1 1 $57.80 $57.80 $57.80 $57.80 Assumes that 1 hour is spent to prep

site

M21 Monitoring and Data Collection System N/A N/A N/A N/A $25,300.00 $25,300.00 $25,300.00 Includes cost of M21monitoring dev

($14,500)

First Year Total Hours and Cost per Facility 118 $30,907 $30,907 $30,907 Includes read rule and instructions, 

first yearsurvey and notification of 

Well Site Level Costs

Subsequent Activities Planning 2 12 24 $57.80 $1,387.20 $1,387.20 $1,387.20 Hours from PES Memorandumb

Method 21 Survey 2 8 16 $57.80 $924.80 $1,849.60 $3,699.20 Assumes 2 people and 8 hours per p

monitoring device for each survey

Repair Costs N/A N/A N/A N/A $29,288.02 $29,288.02 $29,288.02 Assumes 7.49% or 393 total leaks fo

hours *$66.24/hr) and 98 fixed offlin

M21 Resurvey Costs N/A N/A N/A N/A $196.00 $196.00 $196.00 Resurvey costs assume cost of $2.00 

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to p

and includes storing/filing of record

Annual Hours and Cost per Facility 20 $32,027 $32,952 $34,802 Sum of planning, monitoring, repair

Annual Cost with Amortized Capital Cost $37,203 $38,128 $39,978 Annual cost and first year cost per fa

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 for general and operation manab Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAPc The 22 well si tes per natural gas production company was derived from the City of Fort Worth Natural Gas Air Quality Study, July 2011.e The component resurvey cost based on the average subsequent monitoring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Led The leak percentage was calculated using the baseline SOCMI emission rate (0.00597 kg/hr/source) and the average leak rate to fraction leaking equations for 10,000 ppmv leak definition in Table 5‐4 of the EPA P

No data was available that included monitoring frequency, therefore it was assumed that the leak percentage represented the total annual leaks found using Method 21.
A‐9

Table A-5. Cost of Implementing Equipment Leak Monitoring Program at a Compressor Station 

(Assumes fugitive emissions monitoring using Method 21 (2,500 ppm Leak Definition)) 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Total

Cost ($/year)

Semiannual

Total Cost

($/year)

Quarterly

Total Cost

($/year)

C

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Not

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitori

people and hours from PES Memora

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (Not

Notification of Initial Compliance Status 1 1 1 $57.80 $57.80 $57.80 $57.80 Assumes that 1 hour is spent to prep

site

M21 Monitoring and Data Collection System N/A N/A N/A N/A $25,300.00 $25,300.00 $25,300.00 Includes cost of M21monitoring dev

($14,500)

First Year Total Hours and Cost per Facility 118 $30,907 $30,907 $30,907 Includes read rule and instructions, 

first yearsurvey and notification of 

Well Site Level Costs

Subsequent Activities Planning 2 12 24 $57.80 $1,387.20 $1,387.20 $1,387.20 Hours from PES Memorandumb

Method 21 Survey 2 8 16 $57.80 $924.80 $1,849.60 $3,699.20 Assumes 2 people and 8 hours per p

monitoring device for each survey

Repair Costs N/A N/A N/A N/A $47,821.31 $47,821.31 $47,821.31 Assumes 12.25% or 642 total leaks fo

hours *$66.24/hr) and 160 fixed offl

M21 Resurvey Costs N/A N/A N/A N/A $320.00 $320.00 $320.00 Resurvey costs assume cost of $2.00 

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to p

and includes storing/filing of record

Annual Hours and Cost per Facility 20 $50,685 $51,609 $53,459 Sum of planning, monitoring, repair

Annual Cost with Amortized Capital Cost $55,860 $56,785 $58,635 Annual cost and first year cost per fa

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 for general and operation manab Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAPc The 22 well si tes per natural gas production company was derived from the City of Fort Worth Natural Gas Air Quality Study, July 2011.e The component resurvey cost based on the average subsequent monitoring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Led The leak percentage was calculated using the baseline SOCMI emission rate (0.00597 kg/hr/source) and the average leak rate to fraction leaking equations for 10,000 ppmv leak definition in Table 5‐4 of the EPA P

No data was available that included monitoring frequency, therefore it was assumed that the leak percentage represented the total annual leaks found using Method 21.
A‐10

Table A-6. Cost of Implementing Equipment Leak Monitoring Program at a Compressor Station 

(Assumes fugitive emissions monitoring using Method 21 (500 ppm Leak Definition)) 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Total

Cost ($/year)

Semiannual

Total Cost

($/year)

Quarterly

Total Cost

($/year)

C

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Not

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitori

people and hours from PES Memora

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (Not

Notification of Initial Compliance Status 1 1 1 $57.80 $57.80 $57.80 $57.80 Assumes that 1 hour is spent to prep

site

M21 Monitoring and Data Collection System N/A N/A N/A N/A $25,300.00 $25,300.00 $25,300.00 Includes cost of M21monitoring dev

($14,500)

First Year Total Hours and Cost per Facility 118 $30,907 $30,907 $30,907 Includes read rule and instructions, 

first yearsurvey and notification of 

Well Site Level Costs

Subsequent Activities Planning 2 12 24 $57.80 $1,387.20 $1,387.20 $1,387.20 Hours from PES Memorandumb

Method 21 Survey 2 8 16 $57.80 $924.80 $1,849.60 $3,699.20 Assumes 2 people and 8 hours per p

monitoring device for each survey

Repair Costs N/A N/A N/A N/A $52,899.93 $52,899.93 $52,899.93 Assumes 13.53% or 710 total leaks fo

hours *$66.24/hr) and 177 fixed offl

M21 Resurvey Costs N/A N/A N/A N/A $354.00 $354.00 $354.00 Resurvey costs assume cost of $2.00 

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to p

and includes storing/filing of record

Annual Hours and Cost per Facility 20 $55,797 $56,722 $58,572 Sum of planning, monitoring, repair

Annual Cost with Amortized Capital Cost $60,973 $61,898 $63,747 Annual cost and first year cost per fa

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 for general and operation manab Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAPc The 22 well si tes per natural gas production company was derived from the City of Fort Worth Natural Gas Air Quality Study, July 2011.e The component resurvey cost based on the average subsequent monitoring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Led The leak percentage was calculated using the baseline SOCMI emission rate (0.00597 kg/hr/source) and the average leak rate to fraction leaking equations for 10,000 ppmv leak definition in Table 5‐4 of the EPA P

No data was available that included monitoring frequency, therefore it was assumed that the leak percentage represented the total annual leaks found using Method 21.
A‐11

Table A-7. Cost of Implementing OGI Monitoring Program at a Well Site 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Cost

($/year)

Semiannual

Cost ($/year)

Quarterly

Cost ($/year) Commen

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Note: one ti

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitoring plan. 

people and hours from PES Memorandumb (

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (Note: one ti

Notification of Initial Compliance Status 1 1 1 $57.80 $1,271.60 $1,271.60 $1,271.60 Assumes that 1 hour is spent to prepare the 

well sites

M21 Monitoring Device N/A N/A N/A N/A $10,800.00 $10,800.00 $10,800.00 Includes cost of M21monitoring device ($10

First Year Total Hours and Cost per Company 118 $17,620 $17,620 $17,620 Includes read rule and instructions, monitor

initial survey and notification of initial comp

First Year Total Hours and Cost per Well Site 5.4 $801 $801 $801 Assumes company owns 22 well sitesc

Well Site Level CostsSubsequent Activities Planning 2 12 24 $57.80 $63.05 $63.05 $63.05 Hours from PES Memorandumb. Total cost o

of well sites per company

OGI Camera Survey N/A N/A N/A N/A $600.00 $1,200.00 $2,400.00 Cost from CL Reportd (outside contractor, we

Repair Costs N/A N/A N/A N/A $298.74 $597.48 $1,194.97 Assumes 1.18% or 4 total leaks found persur

*$66.24/hr) and 1 fixed offline (1 * 4.0 hours 

OGI Camera Resurvey (M21 Device) N/A N/A N/A N/A $2.00 $4.00 $8.00 Resurvey costs assume cost of $2.00 per com

repairf

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to prepare th

and includes storing/filing of records

Annual Hours and Cost per Well Site 4 $1,195 $2,096 $3,897 Sum of planning, monitoring, reporting and 

Annual Cost with Amortized Capital Cost $1,329 $2,230 $4,031 First year cost per well site cost amortized o

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 for

general and operations managers.

b Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAPc The 22 well sites per natural gas production company was derived from the City of Fort Worth Natural Gas Air Quality Study, July 2011.d OGI monitoring cost obtained from Appendix 1 in the Carbon Limits Report CL‐13‐27, Quantifying Cost‐effectiveness of Systematic Leak Detection and Repair Programs Using Infrared Camerase The leak percentage was obtained from Table 5 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011.f The component resurvey cost based on the average subsequent monitoring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques f
A‐12

Table A-8. Cost of Implementing OGI Monitoring Program at a Compressor Station (Gathering and Boostin

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Cost

($/year)

Semiannual

Cost ($/year)

Quarterly

Cost ($/year) Commen

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Note: one ti

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitoring plan. 

people and hours from PES Memorandumb (

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (Note: one ti

Notification of Initial Compliance Status 1 1 1 $57.80 $57.80 $57.80 $57.80 Assumes that 1 hour is spent to prepare the 

site

M21 Monitoring Device N/A N/A N/A N/A $10,800.00 $10,800.00 $10,800.00 Includes cost of M21monitoring device ($10

First Year Total Hours and Cost per Company 118 $16,407 $16,407 $16,407 Includes read rule and instructions, monitor

notification of initial compliance status, and 

Compressor Station Costs

Subsequent Activities Planning 2 12 24 $57.80 $1,387.20 $1,387.20 $1,387.20 Hours from PES Memorandumb

OGI Camera Survey N/A N/A N/A N/A $2,300.00 $4,600.00 $9,200.00 Cost from CL Reportc (outside contractor, com

survey; 2*$2,300 forsemi‐annual survey; 4*$

Repair Costs N/A N/A N/A N/A $3,435.54 $6,871.08 $13,742.15 Assumes 1.18% or 46 total leaks found persu

hours *$66.24/hr) and 11 fixed offline (11.5 * 

OGI Camera Resurvey (M21 Device) N/A N/A N/A N/A $22.00 $44.00 $88.00 Resurvey costs assume cost of $2.00 per com

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to prepare th

compressorstation and includes storing/filin

Annual Hours and Cost per Well Site 4 $7,376 $13,133 $24,649 Sum of planning, monitoring, reporting and 

Annual Cost with Amortized Capital Cost $10,124 $15,881 $27,396 First year cost per well site cost amortized o

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 for

general and operations managers.

b Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAP

c OGI monitoring cost obtained from Appendix 1 in the Carbon Limits Report CL‐13‐27, Quantifying Cost‐effectiveness of Systematic Leak Detection and RepaOGI Programs Using Infrared Cameras

d The leak percentage was obtained from Table 5 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011.e The component resurvey cost based on the average subsequent monitoring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques f
A‐13

Table A-9. Cost of Implementing OGI Monitoring Program at a Compressor Station (Transmission) 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Cost

($/year)

Semiannual

Cost ($/year)

Quarterly

Cost ($/year) Commen

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Note: one ti

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitoring plan. 

people and hours from PES Memorandumb (

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (Note: one ti

Notification of Initial Compliance Status 1 1 1 $57.80 $57.80 $57.80 $57.80 Assumes that 1 hour is spent to prepare the 

site

M21 Monitoring Device N/A N/A N/A N/A $10,800.00 $10,800.00 $10,800.00 Includes cost of M21monitoring device ($10

First Year Total Hours and Cost per Company 118 $16,407 $16,407 $16,407 Includes read rule and instructions, monitor

notification of initial compliance status, and 

Compressor Station Costs

Subsequent Activities Planning 2 12 24 $57.80 $1,387.20 $1,387.20 $1,387.20 Hours from PES Memorandumb

OGI Camera Survey N/A N/A N/A N/A $2,300.00 $4,600.00 $9,200.00 Cost from CL Reportc (outside contractor, com

survey; 2*$2,300 forsemi‐annual survey; 4*$

RepaOGI Costs N/A N/A N/A N/A $3,360.85 $6,721.70 $13,443.41 Assumes 1.18% or 45 total leaks found persu

hours *$66.24/hr) and 11 fixed offline (11 * 4

OGI Camera Resurvey (M21 Device) N/A N/A N/A N/A $22.00 $44.00 $88.00 Resurvey costs assume cost of $2.00 per com

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to prepare th

compressorstation and includes storing/filin

Annual Hours and Cost per Well Site 4 $7,301 $12,984 $24,350 Sum of planning, monitoring, reporting, stor

Annual Cost with Amortized Capital Cost $10,049 $15,732 $27,097 Cost per compressorstation amortized over 

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 for

general and operations managers.

b Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAP

c OGI monitoring cost obtained from Appendix 1 in the Carbon Limits Report CL‐13‐27, Quantifying Cost‐effectiveness of Systematic Leak Detection and RepaOGI Programs Using Infrared Cameras

d The leak percentage was obtained from Table 5 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011.e The component resurvey cost based on the average subsequent monitoring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques f
A‐14

Table A-10. Cost of Implementing OGI Monitoring Program at a Compressor Station (Storage) 

Item

Number of

People

Number of

Hours per

Person

Total Hours

Labor Cost

($/hour)a

Annual Cost

($/year)

Semiannual

Cost ($/year)

Quarterly

Cost ($/year) Commen

Company Level Costs

Read rule and instructions 1 4 4 $57.80 $231.20 $231.20 $231.20 Hours from PES Memorandumb (Note: one ti

Development of Equipment Leaks Monitoring Plan 2.5 24 60 $57.80 $3,468.00 $3,468.00 $3,468.00 Estimated cost to develop monitoring plan. 

people and hours from PES Memorandumb (

Initial Activities Planning 2 16 32 $57.80 $1,849.60 $1,849.60 $1,849.60 Hours from PES Memorandumb (Note: one ti

Notification of Initial Compliance Status 1 1 1 $57.80 $57.80 $57.80 $57.80 Assumes that 1 hour is spent to prepare the 

site

M21 Monitoring Device N/A N/A N/A N/A $10,800.00 $10,800.00 $10,800.00 Includes cost of M21monitoring device ($10

First Year Total Hours and Cost per Company 118 $16,407 $16,407 $16,407 Includes read rule and instructions, monitor

notification of initial compliance status, and 

Compressor Station Costs

Subsequent Activities Planning 2 12 24 $57.80 $1,387.20 $1,387.20 $1,387.20 Hours from PES Memorandumb

OGI Camera Survey N/A N/A N/A N/A $2,300.00 $4,600.00 $9,200.00 Cost from CL Reportc (outside contractor, com

survey; 2*$2,300 forsemi‐annual survey; 4*$

RepaOGI Costs N/A N/A N/A N/A $6,945.76 $13,891.52 $27,783.04 Assumes 1.18% or 93 total leaks found persu

hours *$66.24/hr) and 11 fixed offline (23 * 4

OGI Camera Resurvey (M21 Device) N/A N/A N/A N/A $22.00 $44.00 $88.00 Resurvey costs assume cost of $2.00 per com

repaire

Annual Report 1 4 4 $57.80 $231.20 $231.20 $231.20 Assumes that 4 hours are spent to prepare th

compressorstation and includes storing/filin

Annual Hours and Cost per Well Site 4 $10,886 $20,154 $38,689 Sum of planning, monitoring, reporting, stor

Annual Cost with Amortized Capital Cost $13,634 $22,902 $41,437 Cost per compressorstation amortized over 

a Costs obtained from Table 11 in the Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011 for

general and operations managers.

b Hours obtained from Attachment 7 in the Memorandum from Ken Meardon, PES to John Schaefer, EPA, Equipment Leak Analysis for Amino and Phenolic Resins NESHAPc OGI monitoring cost obtained from Appendix 1 in the Carbon Limits Report CL‐13‐27, Quantifying Cost‐effectiveness of Systematic Leak Detection and RepaOGI Programs Using Infrared Camerasd The leak percentage was obtained from Table 5 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques for Equipment Leaks, December 21, 2011.e The component resurvey cost based on the average subsequent monitoring fee in Table 13 of Memorandum from Cindy Hancy, RTI to Jodi Howard, EPA, Analysis of Emission Reductions Techniques f
A‐15

Table A-11. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 MonLeak Definition; Single Pollutant) Table A-12. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 Moni

Leak Definition; Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/o

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

HAP

Emissions

(Tons/yr)

HAP Emission

Reductions

(Tons/yr)

HAP Cos

Effectiven

($/Ton

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 0.0475 ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $5,407 $5,407 1.50 3.04 $1,778 0.416 0.845 $6,396 0.0157 0.0318 $16

Semiannual Monitoring $1,460 $4,482 $4,482 1.27 3.27 $1,371 0.353 0.908 $4,934 0.0133 0.0342 $13

Annual Monitoring $1,460 $4,020 $4,020 0.82 3.72 $1,080 0.227 1.035 $3,885 0.0086 0.0390 $10

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 0.0114 ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $5,407 $5,407 0.36 0.73 $7,421 0.100 0.203 $26,696 0.0038 0.0076 $70

Semiannual Monitoring $1,460 $4,482 $4,482 0.30 0.78 $5,724 0.085 0.218 $20,593 0.0032 0.0082 $54

Annual Monitoring $1,460 $4,020 $4,020 0.20 0.89 $4,508 0.054 0.248 $16,216 0.0021 0.0093 $43

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company. total Quarte2 Annual cost includes monitoring cost of $3,755 for annual, $4,218 for semiannual and $5,143 for quarterly and amortization of capital cost over 8 years at 7% interest. total Semi A3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf. total Annual 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emi

(To

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $5,407 $705 $4,702 1.50 3.04 $1,546 0.416 0.845 $5,562 Semiannual Monitoring $1,460 $4,482 $758 $3,725 1.27 3.27 $1,140 0.353 0.908 $4,100 

Annual Monitoring $1,460 $4,020 $863 $3,157 0.82 3.72 $848 0.227 1.035 $3,051 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $5,407 $169 $5,238 0.36 0.73 $7,189 0.100 0.203 $25,862 

Semiannual Monitoring $1,460 $4,482 $182 $4,301 0.30 0.78 $5,493 0.085 0.218 $19,759 

Annual Monitoring $1,460 $4,020 $207 $3,813 0.20 0.89 $4,276 0.054 0.248 $15,383 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes monitoring cost of $3,755 for annual, $4,218 for semiannual and $5,143 for quarterly and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐16

Table A-13. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 MonLeak Definition; Multi-Pollutant) Table A-14. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 Moni

Leak Definition; Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emi

(To

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $5,407 $5,407 1.50 3.04 $889 0.416 0.845 $3,198 Semiannual Monitoring $1,460 $4,482 $4,482 1.27 3.27 $686 0.353 0.908 $2,467 

Annual Monitoring $1,460 $4,020 $4,020 0.82 3.72 $540 0.227 1.035 $1,943 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $5,407 $5,407 0.36 0.73 $3,710 0.100 0.203 $13,348 

Semiannual Monitoring $1,460 $4,482 $4,482 0.30 0.78 $2,862 0.085 0.218 $10,297 

Annual Monitoring $1,460 $4,020 $4,020 0.20 0.89 $2,254 0.054 0.248 $8,108 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes monitoring cost of $3,755 for annual, $4,218 for semiannual and $5,143 for quarterly and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emi

(To

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $5,407 $705 $4,702 1.50 3.04 $773 0.416 0.845 $2,781 Semiannual Monitoring $1,460 $4,482 $758 $3,725 1.27 3.27 $570 0.353 0.908 $2,050 

Annual Monitoring $1,460 $4,020 $863 $3,157 0.82 3.72 $424 0.227 1.035 $1,526 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $5,407 $169 $5,238 0.36 0.73 $3,594 0.100 0.203 $12,931 

Semiannual Monitoring $1,460 $4,482 $182 $4,301 0.30 0.78 $2,746 0.085 0.218 $9,880 

Annual Monitoring $1,460 $4,020 $207 $3,813 0.20 0.89 $2,138 0.054 0.248 $7,691 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes monitoring cost of $3,755 for annual, $4,218 for semiannual and $5,143 for quarterly and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐17

Table A-15. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 MonLeak Definition; Single Pollutant) Table A-16. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 MonDefinition; Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

HAP

Emissions

(Tons/yr)

HAP Emission

Reductions

(Tons/yr)

HAP Cos

Effectiven

($/Ton)

Model Plant

Baseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 0.0475 ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,490 $7,490 0.50 4.04 $1,854 0.139 1.123 $6,669 0.0052 0.0423 $17

Semiannual Monitoring $1,460 $6,565 $6,565 0.36 4.18 $1,572 0.101 1.161 $5,655 0.0038 0.0437 $15

Annual Monitoring $1,460 $6,103 $6,103 0.27 4.27 $1,430 0.076 1.186 $5,145 0.0029 0.0447 $13

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 0.0114 ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,490 $7,490 0.12 0.97 $7,738 0.033 0.269 $27,838 0.0013 0.0101 $73

Semiannual Monitoring $1,460 $6,565 $6,565 0.09 1.00 $6,562 0.024 0.278 $23,605 0.0009 0.0105 $62

Annual Monitoring $1,460 $6,103 $6,103 0.07 1.02 $5,970 0.018 0.284 $21,475 0.0007 0.0107 $57

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company. total Quarte2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $5,824, $6,286 and $7,211 respectively and amortization of capital cost over 8 years at 7% interest. total Semi An3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf. total Annual 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emi

(Ton

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,490 $936 $6,553 0.50 4.04 $1,622 0.139 1.123 $5,835 

Semiannual Monitoring $1,460 $6,565 $968 $5,597 0.36 4.18 $1,340 0.101 1.161 $4,821 

Annual Monitoring $1,460 $6,103 $989 $5,113 0.27 4.27 $1,198 0.076 1.186 $4,311 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,490 $224 $7,265 0.12 0.97 $7,506 0.033 0.269 $27,004 

Semiannual Monitoring $1,460 $6,565 $232 $6,333 0.09 1.00 $6,330 0.024 0.278 $22,771 

Annual Monitoring $1,460 $6,103 $237 $5,866 0.07 1.02 $5,738 0.018 0.284 $20,642 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $5,824, $6,286 and $7,211 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐18

Table A-17. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 MonLeak Definition; Multi-Pollutant) Table A-18. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 MonDefinition; Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emi

(Ton

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,490 $7,490 0.50 4.04 $927 0.139 1.123 $3,335 

Semiannual Monitoring $1,460 $6,565 $6,565 0.36 4.18 $786 0.101 1.161 $2,828 

Annual Monitoring $1,460 $6,103 $6,103 0.27 4.27 $715 0.076 1.186 $2,573 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,490 $7,490 0.12 0.97 $3,869 0.033 0.269 $13,919 

Semiannual Monitoring $1,460 $6,565 $6,565 0.09 1.00 $3,281 0.024 0.278 $11,802 

Annual Monitoring $1,460 $6,103 $6,103 0.07 1.02 $2,985 0.018 0.284 $10,738 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $5,824, $6,286 and $7,211 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emi

(Ton

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,490 $936 $6,553 0.50 4.04 $811 0.139 1.123 $2,918 

Semiannual Monitoring $1,460 $6,565 $968 $5,597 0.36 4.18 $670 0.101 1.161 $2,411 

Annual Monitoring $1,460 $6,103 $989 $5,113 0.27 4.27 $599 0.076 1.186 $2,156 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,490 $224 $7,265 0.12 0.97 $3,753 0.033 0.269 $13,502 

Semiannual Monitoring $1,460 $6,565 $232 $6,333 0.09 1.00 $3,165 0.024 0.278 $11,385 

Annual Monitoring $1,460 $6,103 $237 $5,866 0.07 1.02 $2,869 0.018 0.284 $10,321 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $5,824, $6,286 and $7,211 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐19

Table A-19. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 Mon

Definition; Single Pollutant) Table A-20. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 MonDefinition; Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/o

Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

HAP

Emissions

(Tons/yr)

HAP Emission

Reductions

(Tons/yr)

HAP Cos

Effectiven

($/Ton)

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 0.0475 ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,824 $7,824 0.27 4.27 $1,834 0.076 1.186 $6,597 0.0029 0.0447 $17

Semiannual Monitoring $1,460 $6,899 $6,899 0.14 4.40 $1,567 0.038 1.224 $5,637 0.0014 0.0461 $14

Annual Monitoring $1,460 $6,437 $6,437 0.09 4.45 $1,447 0.025 1.237 $5,206 0.0010 0.0466 $13

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 0.0114 ‐‐‐‐‐ Quarterly Monitoring $1,460 $7,824 $7,824 0.07 1.02 $7,654 0.018 0.284 $27,534 0.0007 0.0107 $73

Semiannual Monitoring $1,460 $6,899 $6,899 0.03 1.05 $6,540 0.009 0.293 $23,529 0.0003 0.0110 $62

Annual Monitoring $1,460 $6,437 $6,437 0.02 1.07 $6,040 0.006 0.296 $21,728 0.0002 0.0112 $57

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company. total Quarter2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $6,157, $6,619 and $7,544 respectively and amortization of capital cost over 8 years at 7% interest. total Semi An3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf. total Annual 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emis

(Ton

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,824 $989 $6,835 0.27 4.27 $1,602 0.076 1.186 $5,763 

Semiannual Monitoring $1,460 $6,899 $1,021 $5,879 0.14 4.40 $1,335 0.038 1.224 $4,803 

Annual Monitoring $1,460 $6,437 $1,031 $5,406 0.09 4.45 $1,215 0.025 1.237 $4,372 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,824 $237 $7,587 0.07 1.02 $7,422 0.018 0.284 $26,700 

Semiannual Monitoring $1,460 $6,899 $245 $6,655 0.03 1.05 $6,309 0.009 0.293 $22,695 

Annual Monitoring $1,460 $6,437 $247 $6,190 0.02 1.07 $5,808 0.006 0.296 $20,894 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $6,157, $6,619 and $7,544 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐20

Table A-21. Average Model Plant Cost of Control for Summary Well Pads w/o Recovery Credits – M21 Mon

Definition; Multi-Pollutant) Table A-22. Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – M21 MonDefinition; Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/o

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emis

(Ton

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,824 $7,824 0.27 4.27 $917 0.076 1.186 $3,298 

Semiannual Monitoring $1,460 $6,899 $6,899 0.14 4.40 $783 0.038 1.224 $2,819 

Annual Monitoring $1,460 $6,437 $6,437 0.09 4.45 $724 0.025 1.237 $2,603 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,824 $7,824 0.07 1.02 $3,827 0.018 0.284 $13,767 

Semiannual Monitoring $1,460 $6,899 $6,899 0.03 1.05 $3,270 0.009 0.293 $11,764 

Annual Monitoring $1,460 $6,437 $6,437 0.02 1.07 $3,020 0.006 0.296 $10,864 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $6,157, $6,619 and $7,544 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

H

Emis

(Ton

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,824 $989 $6,835 0.27 4.27 $801 0.076 1.186 $2,881 

Semiannual Monitoring $1,460 $6,899 $1,021 $5,879 0.14 4.40 $668 0.038 1.224 $2,402 

Annual Monitoring $1,460 $6,437 $1,031 $5,406 0.09 4.45 $608 0.025 1.237 $2,186 

Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $1,460 $7,824 $237 $7,587 0.07 1.02 $3,711 0.018 0.284 $13,350 

Semiannual Monitoring $1,460 $6,899 $245 $6,655 0.03 1.05 $3,154 0.009 0.293 $11,348 

Annual Monitoring $1,460 $6,437 $247 $6,190 0.02 1.07 $2,904 0.006 0.296 $10,447 

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $6,157, $6,619 and $7,544 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐21

Table A-23. Nationwide Impacts – Method 21 Monitoring and Repair Plan - 2020 (Well Sites) 

10,000 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Ca

Annual IR MonitoringGas Wells 5,518 $1,460 $4,020 $3,157 20,539 5,709 $1,080 $848 $3,885 $3,051 

Oil Wells 16,562 $1,460 $4,020 $3,813 14,769 4,106 $4,508 $4,276 $16,216 $15,383 $

Semi‐Annual IR Monitoring

Gas Wells 5,518 $1,460 $4,482 $3,725 18,034 5,013 $1,371 $1,140 $4,934 $4,100 

Oil Wells 16,562 $1,460 $4,482 $4,301 12,968 3,605 $5,724 $5,493 $20,593 $19,759 $

Quarterly IR Monitoring

Gas Wells 5,518 $1,460 $5,407 $4,702 16,782 4,665 $1,778 $1,546 $6,396 $5,562 

Oil Wells 16,562 $1,460 $5,407 $5,238 12,068 3,354 $7,421 $7,189 $26,696 $25,862 $

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $3,755, $4,218 and $5,143 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credi ts calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 67% reduction wi th the implementation of annual Method 21 monitoring, 72% reduction with the implementation of semi‐annual moni toring and 82% with the implementation of q

Methane Cost of Control VOC Cost of Control 

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission

Reductions4

Annual Cost

($/yr)2

2,500 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Ca

Annual IR Monitoring

Gas Wells 5,518 $1,460 $6,103 $5,113 23,545 1,732 $1,430 $1,198 $19,445 $16,294 

Oil Wells 16,562 $1,460 $6,103 $5,866 16,931 415 $5,970 $5,738 $243,611 $234,151 $Semi‐Annual IR Monitoring

Gas Wells 5,518 $1,460 $6,565 $5,597 23,044 1,695 $1,572 $1,340 $21,374 $18,222 

Oil Wells 16,562 $1,460 $6,565 $6,333 16,570 406 $6,562 $6,330 $267,767 $258,307 $Quarterly IR Monitoring

Gas Wells 5,518 $1,460 $7,490 $6,553 22,292 1,640 $1,854 $1,622 $25,206 $22,055 

Oil Wells 16,562 $1,460 $7,490 $7,265 16,030 393 $7,738 $7,506 $315,784 $306,325 $

1 Capital cost includes cost for implementing the moni toring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $5,824, $6,286 and $7,211 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credi ts calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 89% reduction with the implementation of annual Method 21 moni toring, 92% reduction with the implementation of semi‐annual monitoring and 94% with the implementation of q

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission

Reductions4 Methane Cost of Control VOC Cost of Control 
A‐22

500 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Ca

Annual IR MonitoringGas Wells 5,518 $1,460 $6,437 $5,406 24,547 1,805 $1,447 $1,215 $19,674 $16,522 

Oil Wells 16,562 $1,460 $6,437 $6,190 17,651 433 $4,343 $4,176 $246,477 $237,017 $

Semi‐Annual IR Monitoring

Gas Wells 5,518 $1,460 $6,899 $5,879 24,296 1,787 $1,567 $1,335 $21,305 $18,153 

Oil Wells 16,562 $1,460 $6,899 $6,655 17,471 428 $6,540 $6,309 $266,906 $257,446 $

Quarterly IR Monitoring

Gas Wells 5,518 $1,460 $7,824 $6,835 23,545 1,732 $1,834 $1,602 $24,932 $21,780 

Oil Wells 16,562 $1,460 $7,824 $7,587 16,931 415 $7,654 $7,422 $312,342 $302,882 $

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $6,157, $6,619 and $7,544 respectively and amortization of capi tal cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 94% reduction with the implementation of annual Method 21 monitoring, 97% reduction with the implementation of semi‐annual monitoring and 98% with the implementation of q

Nationwide Emission

Reductions4 Methane Cost of Control VOC Cost of Control 

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

($/yr)3
A‐23

Table A-24. Nationwide Impacts – Method 21 Monitoring and Repair Plan - 2025 (Well Sites) 

10,000 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Ca

Annual IR MonitoringGas Wells 38,393 $1,460 $4,020 $3,157 142,906 39,724 $1,080 $848 $3,885 $3,051 $

Oil Wells 100,175 $1,460 $4,020 $3,813 89,332 24,832 $4,508 $4,276 $16,216 $15,383 $1Semi‐Annual IR Monitoring

Gas Wells 38,393 $1,460 $4,482 $3,725 125,478 34,880 $1,371 $1,140 $4,934 $4,100 $

Oil Wells 100,175 $1,460 $4,482 $4,301 78,438 21,804 $5,724 $5,493 $20,593 $19,759 $1Quarterly IR Monitoring

Gas Wells 38,393 $1,460 $5,407 $4,702 116,764 32,458 $1,778 $1,546 $6,396 $5,562 $

Oil Wells 100,175 $1,460 $5,407 $5,238 72,991 20,290 $7,421 $7,189 $26,696 $25,862 $1

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $3,755, $4,218 and $5,143 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credi ts calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 67% reduction wi th the implementation of annual Method 21 monitoring, 72% reduction with the implementation of semi‐annual moni toring and 82% with the implementation of q

VOC Cost of Control 

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission

Reductions4 Methane Cost of Control

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

2,500 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Ca

Annual IR MonitoringGas Wells 38,393 $1,460 $6,103 $5,113 163,819 1,732 $1,430 $1,198 $135,297 $113,368 $

Oil Wells 100,175 $1,460 $6,103 $5,866 102,405 415 $5,970 $5,738 $1,473,476 $1,416,259 $1Semi‐Annual IR Monitoring

Gas Wells 38,393 $1,460 $6,565 $5,597 160,333 1,695 $1,572 $1,340 $148,712 $126,783 $

Oil Wells 100,175 $1,460 $6,565 $6,333 100,226 406 $6,562 $6,330 $1,619,584 $1,562,367 $1Quarterly IR Monitoring

Gas Wells 38,393 $1,460 $7,490 $6,553 155,105 1,640 $1,854 $1,622 $175,380 $153,451 $

Oil Wells 100,175 $1,460 $7,490 $7,265 96,958 393 $7,738 $7,506 $1,910,017 $1,852,800 $1

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $5,824, $6,286 and $7,211 respectively and amortization of capi tal cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 89% reduction with the implementation of annual Method 21 monitoring, 92% reduction with the implementation of semi‐annual monitoring and 94% with the implementation of q

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission

Reductions4 Methane Cost of Control VOC Cost of Control 
A‐24

500 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Ca

Annual IR MonitoringGas Wells 38,393 $1,460 $6,437 $5,406 170,790 1,805 $1,447 $1,215.22 $136,888 $114,959 $

Oil Wells 100,175 $1,460 $6,437 $6,190 106,763 433 $3,776 $3,631 $1,490,810 $1,433,593 $1Semi‐Annual IR Monitoring

Gas Wells 38,393 $1,460 $6,899 $5,879 169,047 1,787 $1,567 $1,335 $148,234 $126,305 $

Oil Wells 100,175 $1,460 $6,899 $6,655 105,673 428 $6,540 $6,309 $1,614,374 $1,557,157 $1Quarterly IR Monitoring

Gas Wells 38,393 $1,460 $7,824 $6,835 163,819 1,732 $1,834 $1,602 $173,468 $151,539 $

Oil Wells 100,175 $1,460 $7,824 $7,587 102,405 415 $7,654 $7,422 $1,889,193 $1,831,976 $1

1 Capital cost includes cost for implementing the monitoring program of $32,120 divided between 22 well sites per company.2 Annual cost includes annual, quarterly and semi‐annual monitoring cost of $6,157, $6,619 and $7,544 respectively and amortization of capi tal cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 94% reduction with the implementation of annual Method 21 monitoring, 97% reduction with the implementation of semi‐annual monitoring and 98% with the implementation of q

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission

Reductions4 Methane Cost of Control VOC Cost of Control
A‐25

Table A-25. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/o RecoMonitoring (10,000 ppm Leak Definition) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits ($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

VOC Cost

Effectiveness

($/Ton)

HAP Emissions

(Tons/yr)

HAP Emission

Reductions

(Tons/yr)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.1 ‐‐‐‐‐ ‐‐‐‐‐ 9.77 ‐‐‐‐‐ ‐‐‐‐‐ 0.3680 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $39,978 $39,978 11.6 23.5 $1,698 3.22 6.55 $6,108 0.1215 0.2466 

Semiannual Monitoring $30,907 $38,128 $38,128 9.8 25.3 $1,507 2.74 7.03 $5,421 0.1030 0.2650 

Annual Monitoring $30,907 $37,203 $37,203 6.3 28.8 $1,291 1.76 8.01 $4,644 0.0662 0.3018 

Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.4 ‐‐‐‐‐ ‐‐‐‐‐ 1.73 ‐‐‐‐‐ ‐‐‐‐‐ 0.0513 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $39,978 $39,978 20.6 41.8 $957 0.57 1.16 $34,568 0.0169 0.0344 Semiannual Monitoring $30,907 $38,128 $38,128 17.5 44.9 $849 0.48 1.24 $30,679 0.0144 0.0369 Annual Monitoring $30,907 $37,203 $37,203 11.2 51.1 $727 0.31 1.42 $26,284 0.0092 0.0420 Storage Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.4 ‐‐‐‐‐ ‐‐‐‐‐ 4.55 ‐‐‐‐‐ ‐‐‐‐‐ 0.1352 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $39,978 $39,978 54.3 110.2 $363 1.50 3.05 $13,113 0.0446 0.0906 

Semiannual Monitoring $30,907 $38,128 $38,128 46.0 118.4 $322 1.27 3.28 $11,638 0.0378 0.0973 

Annual Monitoring $30,907 $37,203 $37,203 29.6 134.8 $276 0.82 3.73 $9,971 0.0243 0.1108 

1 Capital cost includes cost for implementing the monitoring program of $30,907. to2 Annual cost includes monitoring cost of $37,007 for annual , $32,756 for semiannual and $34,606 for quarterly frequency and amortization of capital cost over 8 years at 7% interest. to3 Recovery credits calculated assuming the natural gas (92.8% methane) from the methane reduction has a value of $4/Mscf. to
A‐26

Table A-26. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/ RecovMonitoring (10,000 ppm Leak Definition) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits ($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

VOC Cost

Effectiveness

($/Ton)

HAP 

(To

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.1 ‐‐‐‐‐ ‐‐‐‐‐ 9.77 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $39,978 $5,458 $34,519 11.6 23.5 $1,466 3.22 6.55 $5,274 Semiannual Monitoring $30,907 $38,128 $5,865 $32,263 9.8 25.3 $1,275 2.74 7.03 $4,587 

Annual Monitoring $30,907 $37,203 $6,680 $30,523 6.3 28.8 $1,059 1.76 8.01 $3,810 

Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.4 ‐‐‐‐‐ ‐‐‐‐‐ 1.73 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $39,978 $8,654 $31,324 20.6 41.8 $750 0.57 1.16 $27,085 

Semiannual Monitoring $30,907 $38,128 $9,299 $28,828 17.5 44.9 $642 0.48 1.24 $23,196 

Annual Monitoring $30,907 $37,203 $10,591 $26,612 11.2 51.1 $520 0.31 1.42 $18,802 Storage Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.4 ‐‐‐‐‐ ‐‐‐‐‐ 4.55 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $39,978 $22,812 $17,165 54.3 110.2 $156 1.50 3.05 $5,630 

Semiannual Monitoring $30,907 $38,128 $24,514 $13,613 46.0 118.4 $115 1.27 3.28 $4,155 

Annual Monitoring $30,907 $37,203 $27,919 $9,284 29.6 134.8 $69 0.82 3.73 $2,488 

1 Capital cost includes cost for implementing the monitoring program of $30,907.2 Annual cost includes monitoring cost of $37,007 for annual , $32,756 for semiannual and $34,606 for quarterly frequency and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (92.8% methane) from the methane reduction has a value of $4/Mscf.
A‐27

Table A-27. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/o RecoMonitoring (2,500 ppm Leak Definition) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits ($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

VOC Cost

Effectiveness

($/Ton)

HAP Emissions

(Tons/yr)

HAP Emission

Reductions

(Tons/yr)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.1 ‐‐‐‐‐ ‐‐‐‐‐ 9.77 ‐‐‐‐‐ ‐‐‐‐‐ 0.3680 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $58,635 $58,635 3.9 31.3 $1,875 1.07 8.69 $6,744 0.0405 0.3275 

Semiannual Monitoring $30,907 $56,785 $56,785 2.8 32.3 $1,756 0.78 8.99 $6,318 0.0294 0.3386 

Annual Monitoring $30,907 $55,860 $55,860 2.1 33.0 $1,691 0.59 9.18 $6,083 0.0221 0.3459 Transmission Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.4 ‐‐‐‐‐ ‐‐‐‐‐ 1.73 ‐‐‐‐‐ ‐‐‐‐‐ 0.0513 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $58,635 $58,635 6.9 55.5 $1,056 0.19 1.54 $38,168 0.0056 0.0456 

Semiannual Monitoring $30,907 $56,785 $56,785 5.0 57.4 $990 0.14 1.59 $35,758 0.0041 0.0472 

Annual Monitoring $30,907 $55,860 $55,860 3.7 58.6 $953 0.10 1.62 $34,427 0.0031 0.0482 Storage Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.4 ‐‐‐‐‐ ‐‐‐‐‐ 4.55 ‐‐‐‐‐ ‐‐‐‐‐ 0.1352 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $58,635 $58,635 18.1 146.3 $401 0.50 4.05 $14,479 0.0149 0.1203 

Semiannual Monitoring $30,907 $56,785 $56,785 13.2 151.3 $375 0.36 4.19 $13,565 0.0108 0.1243 

Annual Monitoring $30,907 $55,860 $55,860 9.9 154.6 $361 0.27 4.28 $13,060 0.0081 0.1270 

1 Capital cost includes cost for implementing the monitoring program of $30,907. to2 Annual cost includes monitoring cost of $55,797 for annual , $56,722 for semiannual and $55,797 for quarterly frequency and amortization of capital cost over 8 years at 7% interest. to3 Recovery credits calculated assuming the natural gas (92.8% methane) from the methane reduction has a value of $4/Mscf. to
A‐28

Table A-28. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/ RecovMonitoring (2,500 ppm Leak Definition) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits ($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

VOC Cost

Effectiveness

($/Ton)

HAP 

(T

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.1 ‐‐‐‐‐ ‐‐‐‐‐ 9.77 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $58,635 $7,250 $51,385 3.9 31.3 $1,643 1.07 8.69 $5,910 Semiannual Monitoring $30,907 $56,785 $7,495 $49,291 2.8 32.3 $1,525 0.78 8.99 $5,485 Annual Monitoring $30,907 $55,860 $7,658 $48,203 2.1 33.0 $1,459 0.59 9.18 $5,249 

Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.4 ‐‐‐‐‐ ‐‐‐‐‐ 1.73 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $58,635 $11,495 $47,140 6.9 55.5 $849 0.19 1.54 $30,685 Semiannual Monitoring $30,907 $56,785 $11,883 $44,903 5.0 57.4 $783 0.14 1.59 $28,276 

Annual Monitoring $30,907 $55,860 $12,141 $43,719 3.7 58.6 $746 0.10 1.62 $26,945 

Storage Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.4 ‐‐‐‐‐ ‐‐‐‐‐ 4.55 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $58,635 $30,303 $28,332 18.1 146.3 $194 0.50 4.05 $6,996 Semiannual Monitoring $30,907 $56,785 $31,324 $25,461 13.2 151.3 $168 0.36 4.19 $6,082 

Annual Monitoring $30,907 $55,860 $32,005 $23,855 9.9 154.6 $154 0.27 4.28 $5,577 

1 Capital cost includes cost for implementing the monitoring program of $30,907.2 Annual cost includes monitoring cost of $37,007 for annual , $32,756 for semiannual and $34,606 for quarterly frequency and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (92.8% methane) from the methane reduction has a value of $4/Mscf.
A‐29

Table A-29. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/o RecoMonitoring (500 ppm Leak Definition) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits ($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

VOC Cost

Effectiveness

($/Ton)

HAP Emissions

(Tons/yr)

HAP Emission

Reductions

(Tons/yr)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.1 ‐‐‐‐‐ ‐‐‐‐‐ 9.77 ‐‐‐‐‐ ‐‐‐‐‐ 0.3680 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $63,747 $63,747 2.1 33.0 $1,930 0.59 9.18 $6,942 0.0221 0.3459 

Semiannual Monitoring $30,907 $61,898 $61,898 1.1 34.1 $1,816 0.29 9.48 $6,532 0.0110 0.3570 

Annual Monitoring $30,907 $60,973 $60,973 0.7 34.4 $1,770 0.20 9.57 $6,369 0.0074 0.3607 Transmission Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.4 ‐‐‐‐‐ ‐‐‐‐‐ 1.73 ‐‐‐‐‐ ‐‐‐‐‐ 0.0513 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $63,747 $63,747 3.7 58.6 $1,087 0.10 1.62 $39,288 0.0031 0.0482 

Semiannual Monitoring $30,907 $61,898 $61,898 1.9 60.5 $1,023 0.05 1.67 $36,969 0.0015 0.0497 

Annual Monitoring $30,907 $60,973 $60,973 1.2 61.1 $998 0.03 1.69 $36,045 0.0010 0.0502 Storage Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.4 ‐‐‐‐‐ ‐‐‐‐‐ 4.55 ‐‐‐‐‐ ‐‐‐‐‐ 0.1352 ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $63,747 $63,747 9.9 154.6 $412 0.27 4.28 $14,904 0.0081 0.1270 

Semiannual Monitoring $30,907 $61,898 $61,898 4.9 159.5 $388 0.14 4.41 $14,024 0.0041 0.1311 

Annual Monitoring $30,907 $60,973 $60,973 3.3 161.1 $378 0.09 4.46 $13,673 0.0027 0.1324 

1 Capital cost includes cost for implementing the monitoring program of $30,907. to2 Annual cost includes monitoring cost of $55,797 for annual , $56,722 for semiannual and $58,572 for quarterly frequency and amortization of capital cost over 8 years at 7% interest. to3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for T&S) from the methane reduction has a value of $4/Mscf. to
A‐30

Table A-30. Average Model Plant Cost of Control Summary for Transmission & Storage Facilities w/ RecovMonitoring (500 ppm Leak Definition) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits ($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

VOC Cost

Effectiveness

($/Ton)

HAP 

(T

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.1 ‐‐‐‐‐ ‐‐‐‐‐ 9.77 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $63,747 $7,658 $56,090 2.1 33.0 $1,698 0.59 9.18 $6,108 Semiannual Monitoring $30,907 $61,898 $7,902 $53,996 1.1 34.1 $1,584 0.29 9.48 $5,698 Annual Monitoring $30,907 $60,973 $7,983 $52,990 0.7 34.4 $1,539 0.20 9.57 $5,535 

Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.4 ‐‐‐‐‐ ‐‐‐‐‐ 1.73 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $63,747 $12,141 $51,606 3.7 58.6 $880 0.10 1.62 $31,806 Semiannual Monitoring $30,907 $61,898 $12,528 $49,369 1.9 60.5 $816 0.05 1.67 $29,486 

Annual Monitoring $30,907 $60,973 $12,658 $48,315 1.2 61.1 $790 0.03 1.69 $28,562 

Storage Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.4 ‐‐‐‐‐ ‐‐‐‐‐ 4.55 ‐‐‐‐‐ ‐‐‐‐‐ 

Quarterly Monitoring $30,907 $63,747 $32,005 $31,742 9.9 154.6 $205 0.27 4.28 $7,421 Semiannual Monitoring $30,907 $61,898 $33,026 $28,871 4.9 159.5 $181 0.14 4.41 $6,541 

Annual Monitoring $30,907 $60,973 $33,367 $27,606 3.3 161.1 $171 0.09 4.46 $6,191 

1 Capital cost includes cost for implementing the monitoring program of $30,907.2 Annual cost includes monitoring cost of $55,797 for annual , $56,722 for semiannual and $58,572 for quarterly frequency and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for T&S) from the methane reduction has a value of $4/Mscf.
A‐31

Table A-31. Nationwide Impacts – Method 21 Monitoring and Repair Plan - 2020 (Transmission & Storage 

10,000 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Capi

Gathering & Boosting

Quarterly Monitoring 259 $30,907 $39,978 $34,519 6,098 1,695 $1,698 $1,466 $6,108 $5,274 $8

Semiannual Monitoring 259 $30,907 $38,128 $32,263 6,553 1,822 $1,507 $1,275 $5,421 $4,587 $8

Annual Monitoring 259 $30,907 $37,203 $30,523 7,464 2,075 $1,291 $1,059 $4,644 $3,810 $8TransmissionQuarterly Monitoring 6 $30,907 $39,978 $39,978 251 7 $957 $957 $34,568 $34,568 

Semiannual Monitoring 6 $30,907 $38,128 $38,128 269 7 $849 $849 $30,679 $30,679 

Annual Monitoring 6 $30,907 $37,203 $37,203 307 8 $727 $727 $26,284 $26,284 

StorageQuarterly Monitoring 15 $30,907 $39,978 $39,978 1,652 46 $363 $363 $13,113 $13,113 

Semiannual Monitoring 15 $30,907 $38,128 $38,128 1,776 49 $322 $322 $11,638 $11,638 

Annual Monitoring 15 $30,907 $37,203 $37,203 2,022 56 $276 $276 $9,971 $9,971 

1 Capi tal cost includes cost for implementing the monitoring program of $30,907 per company.2 Annual cost includes annual, semiannual and quarterly monitoring cost of $32,027, $38,128 and $39,978 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 82% reduction with the implementation of annual Method 21 moni toring, 72% reduction with the implementation of semi‐annual monitoring and 67% wi th the implementation of quarte

Methane Cost of Control VOC Cost of Control 

Category

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Annual Cost

w/Savings

($/yr)3

Reductions4

2,500 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Capi

Gathering & BoostingQuarterly Monitoring 259 $30,907 $58,635 $51,385 8,101 2,252 $1,875 $1,643 $6,744 $5,910 $8

Semiannual Monitoring 259 $30,907 $56,785 $49,291 8,374 2,328 $1,756 $1,525 $6,318 $5,485 $8

Annual Monitoring 259 $30,907 $55,860 $48,203 8,556 2,378 $1,691 $1,459 $6,083 $5,249 $8TransmissionQuarterly Monitoring 6 $30,907 $58,635 $58,635 333 9 $1,056 $1,056 $38,168 $38,168 Semiannual Monitoring 6 $30,907 $56,785 $56,785 344 10 $990 $990 $35,758 $35,758 

Annual Monitoring 6 $30,907 $55,860 $55,860 352 10 $953 $953 $34,427 $34,427 

StorageQuarterly Monitoring 15 $30,907 $58,635 $58,635 2,195 61 $401 $401 $14,479 $14,479 Semiannual Monitoring 15 $30,907 $56,785 $56,785 2,269 63 $375 $375 $13,565 $13,565 Annual Monitoring 15 $30,907 $55,860 $55,860 2,318 64 $361 $361 $13,060 $13,060 

1 Capi tal cost includes cost for implementing the monitoring program of $30,907 per company.2 Annual cost includes annual, semiannual and quarterly monitoring cost of $50,685, $51,609 and $53,459 respectively and amortization of capi tal cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 94% reduction with the implementation of annual Method 21 monitoring, 92% reduction with the implementation of semi‐annual monitoring and 89% with the implementation of quarte

Category

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Annual Cost

w/Savings

($/yr)3

Reductions4 Methane Cost of Control VOC Cost of Control 
A‐32

500 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Capi

Gathering & BoostingQuarterly Monitoring 259 $30,907 $63,747 $56,090 8,556 2,378 $1,930 $1,698 $6,942 $6,108 $8Semiannual Monitoring 259 $30,907 $61,898 $53,996 8,829 2,454 $1,816 $1,584 $6,532 $5,698 $8Annual Monitoring 259 $30,907 $60,973 $52,990 8,920 2,480 $1,770 $1,539 $6,369 $5,535 $8TransmissionQuarterly Monitoring 6 $30,907 $63,747 $63,747 352 10 $1,087 $1,087 $39,288 $39,288 

Semiannual Monitoring 6 $30,907 $61,898 $61,898 363 10 $1,023 $1,023 $36,969 $36,969 

Annual Monitoring 6 $30,907 $60,973 $60,973 367 10 $998 $998 $36,045 $36,045 

StorageQuarterly Monitoring 15 $30,907 $63,747 $63,747 2,318 64 $412 $412 $14,904 $14,904 

Semiannual Monitoring 15 $30,907 $61,898 $61,898 2,392 66 $388 $388 $14,024 $14,024 Annual Monitoring 15 $30,907 $60,973 $60,973 2,417 67 $378 $378 $13,673 $13,673 

1 Capi tal cost includes cost for implementing the moni toring program of $30,907 per company.2 Annual cost includes annual, semiannual and quarterly moni toring cost of $55,797, $56,722 and $58,572 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 98% reduction with the implementation of annual Method 21 monitoring, 97% reduction with the implementation of semi‐annual monitoring and 94% with the implementation of quart

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission

Reductions4 Methane Cost of Control VOC Cost of Control
A‐33

Table A-32. Nationwide Impacts – Method 21 Monitoring and Repair Plan - 2025 (Transmission & Storage 

10,000 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Cap

Gathering & BoostingQuarterly Monitoring 1,554 $30,907 $39,978 $34,519 36,590 10,171 $1,698 $1,466 $6,108 $5,274 

Semiannual Monitoring 1,554 $30,907 $38,128 $32,263 39,320 10,930 $1,507 $1,275 $5,421 $4,587 Annual Monitoring 1,554 $30,907 $37,203 $30,523 44,781 12,448 $1,291 $1,059 $4,644 $3,810 

TransmissionQuarterly Monitoring 36 $30,907 $39,978 $39,978 1,504 41.6 $957 $957 $34,568 $34,568 

Semiannual Monitoring 36 $30,907 $38,128 $38,128 1,617 44.7 $849 $849 $30,679 $30,679 

Annual Monitoring 36 $30,907 $37,203 $37,203 1,841 51.0 $727 $727 $26,284 $26,284 

StorageQuarterly Monitoring 90 $30,907 $39,978 $39,978 9,914 274.4 $363 $363 $13,113 $13,113 Semiannual Monitoring 90 $30,907 $38,128 $38,128 10,654 294.9 $322 $322 $11,638 $11,638 Annual Monitoring 90 $30,907 $37,203 $37,203 12,134 335.8 $276 $276 $9,971 $9,971 

1 Capital cost includes cost for implementing the monitoring program of $30,907 per company.2 Annual cost includes annual, semiannual and quarterly monitoring cost of $32,027, $38,128 and $39,978 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 82% reduction with the implementation of annual Method 21 monitoring, 72% reduction with the implementation of semi‐annual monitoring and 67% with the implementation of quarterl

Methane Cost of Control VOC Cost of Control 

Category

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Annual Cost

w/Savings

($/yr)3

Reductions4

2,500 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Cap

Gathering & Boosting

Quarterly Monitoring 1,554 $30,907 $58,635 $51,385 48,604 13,511 $1,875 $1,643 $6,744 $5,910 

Semiannual Monitoring 1,554 $30,907 $56,785 $49,291 50,243 13,966 $1,756 $1,525 $6,318 $5,485 Annual Monitoring 1,554 $30,907 $55,860 $48,203 51,335 14,270 $1,691 $1,459 $6,083 $5,249 

TransmissionQuarterly Monitoring 36 $30,907 $58,635 $58,635 1,998 55.3 $1,056 $1,056 $38,168 $38,168 

Semiannual Monitoring 36 $30,907 $56,785 $56,785 2,066 57.2 $990 $990 $35,758 $35,758 Annual Monitoring 36 $30,907 $55,860 $55,860 2,111 58.4 $953 $953 $34,427 $34,427 

StorageQuarterly Monitoring 90 $30,907 $58,635 $58,635 13,170 364.5 $401 $401 $14,479 $14,479 

Semiannual Monitoring 90 $30,907 $56,785 $56,785 13,614 376.8 $375 $375 $13,565 $13,565 Annual Monitoring 90 $30,907 $55,860 $55,860 13,910 385.0 $361 $361 $13,060 $13,060 

1 Capital cost includes cost for implementing the monitoring program of $30,907 per company.2 Annual cost includes annual, semiannual and quarterly monitoring cost of $50,685, $51,609 and $53,459 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 94% reduction with the implementation of annual Method 21 monitoring, 92% reduction with the implementation of semi‐annual monitoring and 89% with the implementation of quarterl

VOC Cost of Control 

Category

Estimated

Annual

Number of

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

Nationwide Emission Methane Cost of Control
A‐34

500 Leak Detection

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Cap

Gathering & Boosting

Quarterly Monitoring 1,554 $30,907 $63,747 $56,090 51,335 14,270 $1,930 $1,698 $6,942 $6,108 

Semiannual Monitoring 1,554 $30,907 $61,898 $53,996 52,973 14,725 $1,816 $1,584 $6,532 $5,698 Annual Monitoring 1,554 $30,907 $60,973 $52,990 53,519 14,877 $1,770 $1,539 $6,369 $5,535 

TransmissionQuarterly Monitoring 36 $30,907 $63,747 $63,747 2,111 58.4 $1,087 $1,087 $39,288 $39,288 

Semiannual Monitoring 36 $30,907 $61,898 $61,898 2,178 60.3 $1,023 $1,023 $36,969 $36,969 Annual Monitoring 36 $30,907 $60,973 $60,973 2,200 60.9 $998 $998 $36,045 $36,045 

StorageQuarterly Monitoring 90 $30,907 $63,747 $63,747 13,910 385.0 $412 $412 $14,904 $14,904 

Semiannual Monitoring 90 $30,907 $61,898 $61,898 14,354 397.2 $388 $388 $14,024 $14,024 Annual Monitoring 90 $30,907 $60,973 $60,973 14,502 401.3 $378 $378 $13,673 $13,673 

1 Capital cost includes cost for implementing the monitoring program of $30,907 per company.2 Annual cost includes annual, semiannual and quarterly monitoring cost of $55,797, $56,722 and $58,572 respectively and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 98% reduction with the implementation of annual Method 21 monitoring, 97% reduction with the implementation of semi‐annual monitoring and 94% with the implementation of quarter

Category

Estimated

Annual

Number of

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

Nationwide Emission Methane Cost of Control VOC Cost of Control
A‐35

Table A-33. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – An(Single Pollutant) Table A-34. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Ann(Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $1,329 $1,329 2.72 1.82 $732 0.757 0.505 $2,633 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $1,329 $1,329 0.65 0.44 $3,055 0.181 0.121 $10,992 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $1,195 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $1,329 $421 $908 2.72 1.82 $500 0.757 0.505 $1,799 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $1,329 $101 $1,228 0.65 0.44 $2,824 0.181 0.121 $10,158 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $1,195 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐36

Table A-35. OGI- Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – An

(Multi-Pollutant) Table A-36. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Ann(Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $1,329 $1,329 2.72 1.82 $366 0.757 0.505 $1,317 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $1,329 $1,329 0.65 0.44 $1,528 0.181 0.121 $5,496 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $1,195 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $1,329 $421 $908 2.72 1.82 $250 0.757 0.505 $900 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $1,329 $101 $1,228 0.65 0.44 $1,412 0.181 0.121 $5,079 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $1,195 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐37

Table A-37. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – Se

Monitoring (Single Pollutant) Table A-38. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Sem

Monitoring (Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $2,230 $2,230 1.82 2.72 $819 0.505 0.757 $2,945 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $2,230 $2,230 0.44 0.65 $3,417 0.121 0.181 $12,294 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $2,096 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $2,230 $631 $1,599 1.82 2.72 $587 0.505 0.757 $2,111 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $2,230 $151 $2,079 0.44 0.65 $3,186 0.121 0.181 $11,460 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $2,096 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐38

Table A-39. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – Se

Monitoring (Multi-Pollutant) Table A-40. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Sem

Monitoring (Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $2,230 $2,230 1.82 2.72 $409 0.505 0.757 $1,473 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $2,230 $2,230 0.44 0.65 $1,709 0.121 0.181 $6,147 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $2,096 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $2,230 $631 $1,599 1.82 2.72 $293 0.505 0.757 $1,056 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $2,230 $151 $2,079 0.44 0.65 $1,593 0.121 0.181 $5,730 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $2,096 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐39

Table A-41. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – Qu(Single Pollutant) Table A-42. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Qua(Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/oRecovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $4,031 $4,031 0.91 3.63 $1,110 0.252 1.009 $3,994 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $4,031 $4,031 0.22 0.87 $4,634 0.060 0.242 $16,669 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $3,897 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits ‐ Quarterly OGI Monitoring

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $4,031 $842 $3,190 0.91 3.63 $878 0.252 1.009 $3,160 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $4,031 $202 $3,830 0.22 0.87 $4,402 0.060 0.242 $15,836 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $3,897 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐40

Table A-43. OGI - Average Model Plant Cost of Control Summary for Well Pads w/o Recovery Credits – Qu(Multi-Pollutant) Table A-44. OGI - Average Model Plant Cost of Control Summary for Well Pads w/ Recovery Credits – Qua(Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/o

Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $4,031 $4,031 0.91 3.63 $555 0.252 1.009 $1,997 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $4,031 $4,031 0.22 0.87 $2,317 0.060 0.242 $8,335 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $3,897 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual LDAR

Cost ($/yr)2

Recovery

Credits

($/yr)3

Annual LDAR

Cost w/

Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

E

(

Model PlantBaseline ‐ Gas Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 4.54 ‐‐‐‐‐ ‐‐‐‐‐ 1.262 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring ‐ Gas $801 $4,031 $842 $3,190 0.91 3.63 $439 0.252 1.009 $1,580 Baseline ‐ Oil Wells ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 1.09 ‐‐‐‐‐ ‐‐‐‐‐ 0.302 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring ‐ Oil $801 $4,031 $202 $3,830 0.22 0.87 $2,201 0.060 0.242 $7,918 1 Capital cost includes cost for implementing the monitoring program of $17,620 divided between 22 well sites per company.2 Annual cost includes annual monitoring cost of $3,897 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.
A‐41

Table A-45. Nationwide Impacts – OGI Monitoring and Repair Plan - 2020 (Well Sites) Table A-46. Nationwide Impacts – OGI Monitoring and Repair Plan - 2025 (Well Sites) 

Methane(Tons/yr) VOC (Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Ca

Annual OGI Monitoring

Gas Wells 5,518 $801 $1,329 $908 10,019 2,785 $732 $500 $2,633 $1,799 

Oil Wells 16,562 $801 $1,329 $1,228 7,205 2,003 $3,055 $2,824 $10,992 $10,158 Semi‐Annual OGI Monitoring

Gas Wells 5,518 $801 $2,230 $1,599 15,029 4,178 $819 $587 $2,945 $2,111 

Oil Wells 16,562 $801 $2,230 $2,079 10,807 3,004 $3,417 $3,186 $12,294 $11,460 Quarterly OGI Monitoring

Gas Wells 5,518 $801 $4,031 $3,190 20,038 5,570 $1,110 $878 $3,994 $3,160 

Oil Wells 16,562 $801 $4,031 $3,830 14,409 4,005 $4,634 $4,402 $16,669 $15,836 1 Capital cost includes cost for implementing the monitoring program which Includes read rule, monitoring plan, intial activities planning, notification of initial compliance status2 Annual cost includes annual, quarterly orsemi‐annual monitoring, planning, monitoring, storing of records and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 40% reduction with annual OGI camera monitoring, 60% reduction with semi‐annual OGI camera monitoring and 80% with quarterly OGI camera monitoring.

Methane Cost of Control VOC Cost of Control 

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission Reductions4

Annual Cost

($/yr)2

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) Capital Cost

Annual OGI Monitoring

Gas Wells 38,933 $801 $1,329 $908 70,691 19,650 $732 $500 $2,633 $1,799 $31,182,50

Oil Wells 100,175 $801 $1,329 $1,228 43,577 12,113 $3,055 $2,824 $10,992 $10,158 $80,232,89Semi‐Annual OGI Monitoring

Gas Wells 38,933 $801 $2,230 $1,599 106,036 29,475 $819 $587 $2,945 $2,111 $31,182,50

Oil Wells 100,175 $801 $2,230 $2,079 65,365 18,170 $3,417 $3,186 $12,294 $11,460 $80,232,89Quarterly OGI Monitoring

Gas Wells 38,933 $801 $4,031 $3,190 141,381 39,300 $1,110 $878 $3,994 $3,160 $31,182,50

Oil Wells 100,175 $801 $4,031 $3,830 87,153 24,226 $4,634 $4,402 $16,669 $15,836 $80,232,891 Capital cost includes cost for implementing the monitoring program which Includes read rule, monitoring plan, intial activities planning, notification of initial compliance status, 2 Annual cost includes annual, quarterly orsemi‐annual monitoring, planning, monitoring, storing of records and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.4 Assumes 40% reduction with annual OGI camera monitoring, 60% reduction with semi‐annual OGI camera monitoring and 80% with quarterly OGI camera monitoring.

Methane Cost of Control VOC Cost of Control T

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission

Reductions4
A‐42

Table A-47. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/o Recovery CMonitoring (Single Pollutant) Table A-48. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/ Recovery CrMonitoring (Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $10,124 $10,124 21.09 14.06 $720 5.861 3.907 $2,591 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $10,049 $10,049 37.42 24.95 $403 1.036 0.690 $14,554 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $13,634 $13,634 98.65 65.77 $207 2.730 1.820 $7,491 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $7,376 for G&B, $7,301 for transmission, $10,886 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $10,124 $3,259 $6,865 21.09 14.06 $488 5.861 3.907 $1,757 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $10,049 $5,166 $4,882 37.42 24.95 $196 1.036 0.690 $7,071 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $13,634 $13,619 $15 98.65 65.77 $0 2.730 1.820 $8 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $7,376 for G&B, $7,301 for transmission, $10,886 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.
A‐43

Table A-49. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/o R

Annual OGI Monitoring (Multi-Pollutant) Table A-50. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/ Re

OGI Monitoring (Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $10,124 $10,124 21.09 14.06 $360 5.861 3.907 $1,295 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $10,049 $10,049 37.42 24.95 $201 1.036 0.690 $7,277 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $13,634 $13,634 98.65 65.77 $104 2.730 1.820 $3,745 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $7,376 for G&B, $7,301 for transmission, $10,886 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $10,124 $3,259 $6,865 21.09 14.06 $244 5.861 3.907 $878 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $10,049 $5,166 $4,882 37.42 24.95 $98 1.036 0.690 $3,536 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $13,634 $13,619 $15 98.65 65.77 $0 2.730 1.820 $4 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $7,376 for G&B, $7,301 for transmission, $10,886 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.
A‐44

Table A-51. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/o Recovery COGI Monitoring (Single Pollutant) Table A-52. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/ Recovery CrMonitoring (Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $15,881 $15,881 14.06 21.09 $753 3.907 5.861 $2,710 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $15,732 $15,732 24.95 37.42 $420 0.690 1.036 $15,190 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $22,902 $22,902 65.77 98.65 $232 1.820 2.730 $8,388 

1 Capital cost includes cost for implementing the monitoring program of $5,607.2 Annual cost includes annual monitoring cost of $9,654 and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $15,881 $4,888 $10,993 14.06 21.09 $521 3.907 5.861 $1,876 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $15,732 $7,750 $7,982 24.95 37.42 $213 0.690 1.036 $7,707 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $22,902 $20,429 $2,473 65.77 98.65 $25 1.820 2.730 $906 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $13,133 for G&B, $12,984 for transmission, $20,154 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.
A‐45

Table A-53. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/o R

Semiannual OGI Monitoring (Multi-Pollutant) Table A-54. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/ Re

Semiannual OGI Monitoring (Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $15,881 $15,881 14.06 21.09 $377 3.907 5.861 $1,355 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $15,732 $15,732 24.95 37.42 $210 0.690 1.036 $7,595 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $22,902 $22,902 65.77 98.65 $116 1.820 2.730 $4,194 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $13,133 for G&B, $12,984 for transmission, $20,154 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $15,881 $4,888 $10,993 14.06 21.09 $261 3.907 5.861 $938 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $15,732 $7,750 $7,982 24.95 37.42 $107 0.690 1.036 $3,854 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $22,902 $20,429 $2,473 65.77 98.65 $13 1.820 2.730 $453 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $13,133 for G&B, $12,984 for transmission, $20,154 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.
A‐46

Table A-55. OGI - Average Model Plant Cost of Control for Summary Compressor Stations w/o Recovery C

Monitoring (Single Pollutant) Table A-56. OGI - Average Model Plant Cost of Control Summary for Compressor Stations w/o Recovery CMonitoring (Single Pollutant) 

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $27,396 $27,396 7.03 28.11 $974 1.954 7.815 $3,506 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $27,097 $27,097 12.47 49.90 $543 0.345 1.381 $19,623 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $41,437 $41,437 32.88 131.54 $315 0.910 3.640 $11,383 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $24,649 for G&B, $24,350 for transmission, $38,689 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $27,396 $6,517 $20,879 7.03 28.11 $743 1.954 7.815 $2,672 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $27,097 $10,333 $16,765 12.47 49.90 $336 0.345 1.381 $12,140 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $41,437 $27,238 $14,199 32.88 131.54 $108 0.910 3.640 $3,901 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $24,649 for G&B, $24,350 for transmission, $38,689 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.
A‐47

Table A-57. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/o R

Quarterly OGI Monitoring (Multi-Pollutant) Table A-58. OGI - Average Model Plant Cost of Control Summary for Gathering & Boosting Stations w/ Re

Quarterly OGI Monitoring (Multi-Pollutant) 

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $27,396 $27,396 7.03 28.11 $487 1.954 7.815 $1,753 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $27,097 $27,097 12.47 49.90 $272 0.345 1.381 $9,812 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $41,437 $41,437 32.88 131.54 $158 0.910 3.640 $5,692 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $24,649 for G&B, $24,350 for transmission, $38,689 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.

Model Plant

Total Capital

Investment1

Annual Cost

($/yr)2

Recovery

Credits

($/yr)3

Annual Cost

w/o Recovery

Credits ($/yr)

Total CH4

Emissions

(Tons/yr)

Total CH4

Emission

Reductions

(Tons/yr)

CH4 Cost

Effectiveness

($/Ton)

Total VOC

Emissions

(Tons/yr)

Total VOC

Emission

Reductions

(Tons/yr)

VOC Cost

Effectiveness

($/Ton)

Gathering & Boosting Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 35.14 ‐‐‐‐‐ ‐‐‐‐‐ 9.769 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $27,396 $6,517 $20,879 7.03 28.11 $371 1.954 7.815 $1,336 Transmission Model Plant

Baseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 62.37 ‐‐‐‐‐ ‐‐‐‐‐ 1.726 ‐‐‐‐‐ ‐‐‐‐‐ 

OGI Monitoring $16,407 $27,097 $10,333 $16,765 12.47 49.90 $168 0.345 1.381 $6,070 Storage Model PlantBaseline ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ 164.42 ‐‐‐‐‐ ‐‐‐‐‐ 4.550 ‐‐‐‐‐ ‐‐‐‐‐ OGI Monitoring $16,407 $41,437 $27,238 $14,199 32.88 131.54 $54 0.910 3.640 $1,950 

1 Capital cost includes cost for implementing the monitoring program of $16,407.2 Annual cost includes annual monitoring cost of $24,649 for G&B, $24,350 for transmission, $38,689 for storage and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for G&B, 92.8% for transmission and storage) from the methane reduction has a value of $4/Mscf.
A‐48

Table A-59. Nationwide Impacts – OGI Monitoring and Repair Plan - 2020 (Compressor Stations) 

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) C

Annual OGI Monitoring

Gathering & Boosting 259 $16,407 $10,124 $6,865 3,641 1,012 $720 $488 $2,591 $1,757 Transmission 6 $16,407 $10,049 $10,049 150 4 $403 $403 $14,554 $14,554 Storage 15 $16,407 $13,634 $13,634 987 27 $207 $207 $7,491 $7,491 Semi‐Annual OGI Monitoring

Gathering & Boosting 259 $16,407 $15,881 $10,993 5,461 1,518 $753 $521 $2,710 $1,876 

Transmission 6 $16,407 $15,732 $15,732 225 6 $420 $420 $15,190 $15,190 Storage 15 $16,407 $22,902 $22,902 1,480 41 $232 $232 $8,388 $8,388 Quarterly OGI Monitoring

Gathering & Boosting 259 $16,407 $27,396 $20,879 7,282 2,024 $974 $743 $3,506 $2,672 

Transmission 6 $16,407 $27,097 $27,097 299 8 $543 $543 $19,623 $19,623 Storage 15 $16,407 $41,437 $41,437 1,973 55 $315 $315 $11,383 $11,383 

1 Capital cost includes cost for implementing the monitoring program which Includes read rule, monitoring plan, intial activities planning, noti fication of initial compliance status, and purcha2 Annual cost includes annual, quarterly or semi‐annual monitoring, planning, monitoring, storing of records and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for gathering and boosting, 92.8% methane for transmission and storage) from the methane reduction has a value of $4/4 Assumes 40% reduction with annual OGI camera monitoring, 60% reduction with semi‐annual OGI camera monitoring and 80% with quarterly OGI camera monitoring.

VOC Cost of Control 

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Nationwide Emission

Reductions4 Methane Cost of Control

Well Site

Annual Cost

w/Savings

($/yr)3
A‐49

Table A-60. Nationwide Impacts – OGI Monitoring and Repair Plan - 2025 (Gathering & Boosting Stations) 

Methane(Tons/yr)

VOC

(Tons/yr)

w/o Savings

($/Ton)

w/ Savings

($/Ton)

w/o Savings

($/Ton)

w/ Savings

($/Ton) C

Annual OGI Monitoring

Gathering & Boosting 1,554 $16,407 $10,124 $6,865 21,845 6,072 $720 $488 $2,591 $1,757 $Transmission 36 $16,407 $10,049 $10,049 898 25 $403 $403 $14,554 $14,554 Storage 90 $16,407 $13,634 $13,634 5,919 164 $207 $207 $7,491 $7,491 Semi‐Annual OGI Monitoring

Gathering & Boosting 1,554 $16,407 $15,881 $10,993 32,767 9,108 $753 $521 $2,710 $1,876 $

Transmission 36 $16,407 $15,732 $15,732 1,347 37 $420 $420 $15,190 $15,190 Storage 90 $16,407 $22,902 $22,902 8,879 246 $232 $232 $8,388 $8,388 Quarterly OGI Monitoring

Gathering & Boosting 1,554 $16,407 $27,396 $20,879 43,689 12,144 $974 $743 $3,506 $2,672 $

Transmission 36 $16,407 $27,097 $27,097 1,796 50 $543 $543 $19,623 $19,623 Storage 90 $16,407 $41,437 $41,437 11,838 328 $315 $315 $11,383 $11,383 

1 Capital cost includes cost for implementing the monitoring program which Includes read rule, monitoring plan, intial activities planning, noti fication of initial compliance status, and purcha2 Annual cost includes annual, quarterly or semi‐annual monitoring, planning, monitoring, storing of records and amortization of capital cost over 8 years at 7% interest.3 Recovery credits calculated assuming the natural gas (82.9% methane for gathering and boosting, 92.8% methane for transmission and storage) from the methane reduction has a value of $4/4 Assumes 40% reduction with the implementation of annual OGI camera monitoring, 60% reduction with the implementation of semi‐annual OGI camera monitoring and 80% with the implemen

Methane Cost of Control VOC Cost of Control 

Category

Estimated

Annual

Number of

New Sources

Capital Cost

($)1

Annual Cost

($/yr)2

Well Site

Annual Cost

w/Savings

($/yr)3

Nationwide Emission

Reductions4